1. Introduction

(a) Web Site Owner. Kodinga, LLC, TrueURewards, LLC ("TUR") is the owner of this web site ("", "", and ""). TUR can be contacted by mail at P.O. Box 133157 Atlanta, GA 30333 by e-mail at This online privacy notice discloses TUR information practices for this TUR Web Site, including what type of personal identifiable information is requested in order to make a purchase, how the information is used, and with whom the information is shared.

(b) Information Collection. TUR collects certain information from TUR Web Site visitors. This includes, but is not limited to, the home server domain name, e-mail address, computer and web browser, what pages visitor accessed, and limited information about search requests. This information is used to solve technical problems and to calculate overall usage statistics.

(c) Web Site Transactions. At times, TUR will need personal information regarding a customer or a prospect. For example to process an order or provide a subscription, TUR may need to know a customer's name, mailing address, e-mail address and credit card details. It is TUR's intent to inform you now before TUR collects personal information, such as user's name and/or address on the Internet. If you tell us that you do not wish to have this information used as a basis for further contact with you, TUR will respect your wishes.

(d) Third Party Certification. TUR is a member of the [] an independent, nonprofit organization that promotes privacy policies of disclosure and informed consent. TUR also abides by the Safe Harbor framework as set forth by the United States Department of Commerce regarding the collection, use and retention of information collected from the European Union. 2. Personal Information That May Be Collected

(a) Identifying Information. In order to make a purchase or "to access designated subscriber services and /or restricted areas within the TUR Web site", TUR may request a user to provide certain personal identifying information, which may include: name, postal address, e-mail address, User ID name, password, telephone number, facsimile number, method of payment, and, if applicable, credit card number. TUR may request additional information necessary to establish and maintain customer's account.

(b) Service Quality Monitoring. Some Web site transactions may require a customer to telephone TUR, or TUR to call the customer. TUR will not contact you by telephone without your prior consent, except to confirm an order placed online and/or to inform a customer of the status of such order. Customer should be aware that it is TUR's practice to monitor, and in some cases record such calls for staff training or quality assurance purposes.

(c) Minors TUR does not collect or maintain information from users actually known to be under the age of 13, and no part of TUR's Web sites are structured to attract anyone under the age of 13.

(d) Links to Other Web Sites. A TUR Web site may contain links to other web sites. TUR is not responsible for the privacy practices, customer information collected and retained or the content of those other Web sites.

3. Uses Made of the Information

(a) Limited Uses Identified. Without customer's prior consent, TUR will not use your personal identifiable information for any purpose other than that for which it is submitted. TUR uses personal identifiable information to reply to inquiries, handle complaints, provide operational notices and in program record-keeping. TUR also processes billing and business requests related to TUR Web Site participation.

(b) Information Collection. The information you provide to the TUR Web site may also be collected, used, analyzed and/or processed by TUR, or selected third parties on TUR's behalf, for marketing and other business purposes. Before TUR uses the information, however, TUR will notify customers and offer customers the opportunity opt-out if a customer wishes not to have personal identifying information used in this way.

(c) Stored Information Uses. TUR stores the information entered on the TUR Web site". This information is used to compile a customer's purchase history in order to enable TUR to recommend products, services, or special offers that would be of interest to a customer.

(d) Online Advertising. Some companies that help TUR deliver interactive on-line advertising, such as banner ads, may collect and use information about TUR's customers to help TUR better understand the types of advertising or promotions that are most appealing to TUR's customers. After it is collected the information is aggregated so it is not identifiable to a specific individual. If, however, customer would prefer that these companies not collect such information, please mark an "x" on the opt-out option box herein provided.

4. Disclosure of the Information

(a) Within Corporate Organization. TUR is a multinational organization, with legal entities, business processes, management structures, and technical systems that cross borders. TUR may share your personal information within the TUR corporate organization, and may transfer the information to countries in the world where TUR conducts business. Some countries may provide less legal protection for customer personal information.

(b) Mergers and Acquisitions. Circumstances may arise where for business reasons, TUR decides to sell, buy, merge or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the disclosure of personal identifying information to prospective or actual purchasers, and/or receiving such information from sellers. It is TUR's practice to seek appropriate protection for information in these types of transactions.

(c) Agents. TUR employs or engages other companies and individuals to perform business functions on behalf of TUR. These persons are provided with personal identifying information required to perform their functions, but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to, fulfilling orders, delivering packages, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments and providing customer services.

(d) Affiliated Businesses. TUR works closely with affiliated businesses operating web site stores, providing services or selling products on each other's Web sites. These businesses identify themselves to customers. Customer information related to a transaction with an affiliated business is shared with that affiliated business.

(e) Marketing Analysis by Third Parties. TUR reserves the right to disclose to third parties personal information about customers for marketing analysis; however, any information disclosed will be in the form of aggregate data that does not describe or identify an individual customer.

(f) Disclosure to Governmental Authorities. Under certain circumstances, personal information may be subject to disclosure pursuant to a judicial or other government subpoenas, warrants or orders.

5. Use of Computer Tracking Technologies

(a) No Tracking of Personal Information. TUR's Web Site(s) are not set up to track, collect or distribute personal information not entered by visitors. Through web site access logs, TUR does collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provides better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties.

(b) Use of Cookies. TUR, or its third party vendors, collect non-identifiable and personal information through the use of various technologies, including "cookies." A cookie is an alphanumeric identifier that a Web site can transfer to customer's hard drive through customer's browser. The cookie is then stored on customer's computer as an anonymous tag that identifies the customer's computer, but not the customer. Cookies may be sent by TUR or its third party vendors. Customer can set its browser to notify customer before a cookie is received, giving an opportunity to decide whether to accept the cookie. Customer may also set its browser to turn off cookies; however, some Web sites may not then work properly.

(c) Use of Web Beacon Technologies. TUR may also use Web beacon or other technologies to better tailor its Web site(s) to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Web site, a non-identifiable notice of that visit is generated which may be processed by TUR or by its suppliers. Web beacons usually work in conjunction with cookies. If customer does not want cookie information to be associated with customer's visits to these pages, customer can set its browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

(d) Collection of Non-Identifiable Information. TUR may collect non-identifiable information from user visits to the TUR Web site(s) in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on TUR Web site(s); Web site and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." TUR or its contractors may use this data to analyze trends and statistics

(e) Collection of Personal Information. TUR collects personal identifying information from customer during a transaction. TUR may extract some personally identifying information about that transaction in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help TUR understand trends and patterns. This information is not reviewed at an individual level.

6. Information Security

(a) Commitment to Online Security. TUR employs physical, electronic and managerial procedures to safeguard the security and integrity of personal information. Billing and payment data is encrypted whenever transmitted or received online. Personal information is accessible only by staff designated to handle online requests or complaints.

(b) No Liability for Acts of Third Parties. TUR will exercise all reasonable efforts to safeguard the confidentiality of customer personal information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, TUR shall not be liable for unauthorized disclosure of personal information due to no fault of TUR including, but not limited to, errors in transmission and unauthorized acts of [TUR staff and/or] third parties.

7. Privacy Policy Changes and Opt-Out Rights

(a) Changes to Privacy Policy. This privacy notice was last updated on November 24, 2013. TUR reserves the right to change its privacy policy statement at any time. A notice of such change will be [prominently] posted on the TUR Web site home page for thirty (30) days prior to the implementation of such change.

(b) Opt-Out Right. Customer has the right at any time to cease permitting personal information to be collected, used or disclosed by TUR and/or by any third parties with whom TUR has shared and/or transferred such personal information. Right of cancellation may be exercised by contacting TUR via e-mail, telephone or certified postal mail. After processing the cancellation, TUR will delete customer or prospective customer's personal information from its data base.

8. Access Rights to Data

(a) Information Maintained by TUR. Upon customer's request, TUR will provide a reasonable description of customer's personally identifiable information that TUR maintains in its data bank. TUR can be contacted by e-mail at, or postal mail to P.O. Box 133157, Atlanta, GA 30333.

(b) Corrections and Changes to Personal Information. Help TUR to keep customer personal information accurate. If customer's personal information changes, or if customer notes an error upon review of customer information that TUR has on file, please promptly e-mail TUR and provide the new or correct information.

9. Accountability

(a) Questions, Problems and Complaints. If you have a question about this policy statement, or a complaint about TUR compliance with this privacy policy, you may contact TUR by e-mail

(b) Terms of Use. If customer chooses to enter into a purchase order or to subscribe to TUR's services, customer's action is hereby deemed acceptance of TUR practices described in this policy statement. Any dispute over privacy between customer and TUR is subject to the provisions of this notice and to TUR's Terms of Use which is hereby incorporated herein and which can be read at [ and].


1. General Content Disclaimer

THE INFORMATION PROVIDED HEREUNDER IS PROVIDED "AS IS." Information Provider makes no warranty or representation regarding the timeliness, content, sequence, accuracy, or completeness of any information or data furnished hereunder.

2. Disclaimer of Warranties


3. Limitation of Liability

Neither TUR nor any of its affiliates, or agents (the "Owner") shall be liable to you or anyone else for any loss or injury arising out of or relating to the information provided on this Web site. In no event will the Owner be liable to you or any third party for any decision made or action taken by you in reliance on the content contained herein. The Owner's liability, if any, arising out of or relating to any kind of legal claim (whether in contract, tort, or otherwise), in any way connected with the content shall be limited to direct damages (excluding, without limitation, consequential, special, incidental, indirect, or similar damages) even if advised of the possibility of such damages, and shall not exceed the amount paid to the Owner for the use of the content in the term immediately preceding the event giving rise to such claim.